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Provider Forum Decisions and Actions
Meeting title:
Green Deal Provider Forum 150327
Date of Meeting:
27h March 2015
Attendees:
Number
Organisation
Name
Type
In attendance
1.
British Gas
Graham Weller
Provider (Chair)
2.
Network Green Deal
Jane Knight
Provider
Neil Pittam Electrical Installations Ltd
Neil Pittam
Provider
Trevor Thompson
Provider
3.
4.
T/A U need Energy
Neil Pittam Electrical Installations Ltd
T/A U need Energy
5.
Solarwise Renewables
Roy Tomkinson
Provider
6.
Westdale Services Ltd
Malcolm Kitching
Provider
7.
DECC
Matt Webb
Government (part)
8.
DECC
Tim Charters
Government (part)
9.
REAL
Mark Cutler
GD ORB (part)
10.
Gemserv
Inga Jirgensone
GD ORB
11.
Gemserv
Louise Evans
GD ORB
1North
Lee Rowlinson
Provider
GoSolar Energy Solutions Ltd (t/a
Elinor Jenkins
Provider
Green Deal Express
Jo Scaiffe
Provider
1.
EDF Energy Customers PLC
David Nutt
Provider
2.
Osborne Energy
Nicole Barrett
Provider
3.
InstaGroup Ltd
Lucy Shadbolt
Provider
4.
MEB Total Limited
Billie Alcock
Provider
5.
Willmott Dixon Energy Services Ltd
David Adams
Provider
6.
Your Green Deal Provider Ltd
John Johnson
Provider
7.
DECC
Ben Golding
Government
Dial-in
12.
13.
14.
Enhance Energy)
Apologies
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8.
DECC
John McKenna
Government
9.
UKSS Renewable Energy Services
Sue Beardmore
Provider
1.
WELCOME AND INTRODUCTIONS
The Chair welcomed everyone to the meeting and invited introductions from the participants.
2.
ACTIONS FROM THE PREVIOUS MEETING
There were four outstanding actions. Updates on these actions and agreed new actions are recorded in
Annex A of these minutes.
Under Action: GDPF 09-04, GD ORB provided some clarification to members on the Consumer Contracts
Regulations (CCR) where definitions of ‘home selling’ and ‘distance selling’ differ to those in Doorstep and
Distance Selling Regulations, an issue which was brought to the attention of the group at the previous
Provider Forum meeting.
The group heard from GD ORB that:

The new cancellation rights set out in the CCR apply to ‘off-premises’ and ‘distance’ contracts –
defined as:
o
Off-premises: if a consumer is asked to sign a contract during a sales visit to their home, elsewhere
or away from the company’s trade premises in the presence of a company representative. Or, the
customer is not given adequate “time to reflect” and is pressured to sign.
o
Distance: contract that has been negotiated and agreed exclusively by distance means (by post or
email). However, an agreement can still be a ‘distance contract’ even if a company representative
visits the customer’s home. For example, if a company representative visits a customer for the sole
purpose of completing a technical survey and then the quote/order form is sent to the customer and
the contract is subsequently completed by post or email.
If a Green Deal Provider visited a customer’s house and left the contract with the customer to sign in their
own time then this would be on premises, and if a Provider were to also state to the customer that the offer
would shortly expire, then that would be classified as ‘distance’ as this action could be considered to be
putting pressure on the customer.
Some concern was expressed about these regulations with regards to Green Deal finance as if a customer
has committed to finance and then changes their mind after the goods have been installed, then the finance
agreement will be void.
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It was argued that the stipulated 14 day calling off period required is not always possible in the renewable
sector as when goods are delivered, particularly in the case of Solar Photovoltaic (SPV), they are also
installed at the same time. It was agreed that while the purpose of the regulations is to harmonise EU law,
the regulations are not entirely practicable in the renewable industry sector.
The group were informed that companies can start installation work before the end of the cancellation
period, but only if the customer gives ‘express permission’ for this. Express permission cannot simply take
the form of a tick box. The Chair requested an example of ‘express permission’ be provided to the forum
members.
Action GDPF 150327-01: GD ORB to circulate a communication to Providers clarifying the Consumer
Contracts Regulations (CCR) requirement of 14 day calling off period and provide a best practice example of
expressed consent form.
3.
GREEN DEAL POLICY SOLUTIONS FOR THE NEXT GOVERNMENT
DECC invited considerations from the group with regards to Green Deal policy solutions for the next
Government and thanked the group for their suggestions that were agreed to be thoughtful and valuable.
The key suggestions of the group were:

Consistency in delivery from point of investment in businesses to the end result. For example, the
changes to ECO in December last year had an adverse impact on many businesses. The Green
Deal Home Improvement Fund (GDHIF) was also provided as an example as the supply chain
inform customers that cashback is available through GDHIF only for the various phases of the fund
to close shortly afterwards. It was, however, noted that this issue has been considerably improved
with the staggered releases of GDHIF funding due to increased visibility of the releases and back
office systems becoming increasingly robust.

Funding must be made available for Solid Wall Insulation due to the cost of installation and the
need for large-scale installation.

Green Deal and other energy efficiency scheme participants should have access to the whole
market of customers. Currently, the options for achieving this are limited in that either:
o
A business can offer a discount for the installation of measures so that the fuel poor can
afford to improve the energy efficiency of their home which is not a feasible business
model for most Providers; or
o
Participants can move into the realm of finance, as is the case with the Green Deal where
some customers do not meet the funding criteria and, again, would be excluded.
These two options prove to be either detrimental to energy efficiency businesses or fuel poor
customers who would benefit most from energy efficiency improvements to their homes. A
suggestion to improve this was to lower the figure for GDHIF and blend the funding with ECO, by
blending funding together between schemes, more customers would be eligible for having
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measures installed and scheme participants would therefore have more of an incentive to be
involved in the Green Deal and the energy efficiency market more generally.

Participants could adopt a ‘whole house’ approach and encourage the installation of multiple
measures.

With regards to the branding of the Green Deal, Forum members suggested that changing the
name of the Green Deal may not be feasible at this stage due to the associated administrative
issues and agreed that the Green Deal has come to be a strong brand.

One participant reminded the group that the initial purpose of the Green Deal is to reduce carbon
emissions which should remain the focus of the scheme.

From a regulatory perspective there should be stricter monitoring of participation in the Green Deal
particularly with regards to the quality of installations. GD ORB informed attendees that improving
the quality of Green Deal installations is a priority for GD ORB and is being progressed via the
technical working groups and also in relation to consumer protection.
4.
FCA AUTHORISATION APPLICATION ISSUES
One Provider suggested that, despite FCA’s approach to assess each individual business model separately
from each other, standardisation of what Providers are required to submit should be in place due to the fact
that Providers must remit Green Deal charges and do not have a choice in this matter as a party to the
GDAA.
GD ORB informed Provider Forum members that the FCA webinar FAQs can now be found on the GD ORB
website here. At the last meeting of the GDAA Panel the issue of FCA authorisation was also discussed and
an action was taken to have a direct joined up session to the discuss FCA requirements in relation to the
GDAA with the intention of making sure the GDAA remains fit for purpose.
Another Provider suggested that Providers submit to the FCA a thorough but simple business process and
that they key is to ensure that the process and procedures followed exactly and are tested against the
organisation’s day to day activities and fit within FCA’s guidelines. This approach is likely to be more
successful than designing a flawless process that is not necessarily practicable.
GD ORB informed the group that there are currently nine Providers with full FCA permissions and will
continue to monitor the progress of Providers in attaining the required permissions.
5.
ASSESSMENT OF BOILERS – HHCRO AND GREEN DEAL
DECC informed the group that a query had been received about a line in the communication concerning
electrical heating and that DECC have been following up over the interpretation of this line.
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Action GDPF 150327-02: DECC to revise the DECC news bulletin Assessment of Boilers – HHCRO and
Green Deal and GD ORB to re-circulate the communication clarifying the change.
One Provider queried whether European Regional Development cannot be blended with ECO or the Green
Deal which, if the case, would be problematic as many authorities rely on a certain amount of blending for
certain projects. GD ORB informed the forum that a similar issue has been formally raised with GDAG and
DECC agreed to investigate the issue and report back to the forum.
Action GDPF 150327-03: GD ORB to clarify with DECC whether European Regional Development Funding
can be blended with ECO and/ or the Green Deal and report back to the forum.
6.
DECC CONSUMER FIRST PROJECT
DECC informed the group that the Consumer First Project is working to ensure that customers are brought
into heart of DECC policy making. This has been developed as part of DECC’s actions in response to the
Government Digital Strategy (https://www.gov.uk/government/publications/department-for-energy-andclimate-change-government-digital-strategy-actions/deccs-actions-in-response-to-the-government-digitalstrategy)
One Provider commended the project and suggested this is a positive way of thinking by having a core team
of people working closely from the beginning of a process and using this to build a digital interface and use
existing data sources more cleverly.
7.
GDAA UPDATE
In the Panel Chair’s absence, GD ORB provided a summary of the key GDAA updates, including:

The GDAA 2015 budget is to be confirmed soon and that the GDAA self-funding will start from 1st
July. From this date, all GDAA parties will be required to contribute the £1000 fixed fee element.
Agreement of the budget has not yet been confirmed in writing but DECC are looking to cover the
remainder of the cost (variable cost) for the remainder of 2015. Next year the variable cost (per
plan) will be paid for by parties to the GDAA.

The GDAA Special Purpose Vehicle (SPV) is scheduled to be in place by 1st July 2015.

The next GDAA Performance Reporting Workshop is scheduled to take place in May 2015. The
group heard from GD ORB that the group has made a lot of progress based on input from parties
on their day to day experiences in respect of reporting.
With regards to the GDAA 2016 budget, one Provider queried whether existing plans up to this point will be
sacrosanct. GD ORB confirmed that the variable cost will be spread across all plans that are currently live
and the idea is that the more plans there are, the smaller the cost will be per plan.
Providers expressed some concern at the additional costs involved that will be applied to each existing plan
as this cost was not factored in at the point of agreeing finance with the customer.
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8.
ISSUES LOG
The Provider Forum members reviewed the issues captured on the current issues log in order to decide
upon the priority issues and identify issues that have been resolved and can be removed from the log. The
following key issues were discussed:

Golden Rule methodology. The IRR-002-GDPF issue cannot be progressed any further until after
the election but Providers reiterated the importance that the issue be addressed.

One Provider requested an update on a reported case of Provider non-compliance and GD ORB
confirmed that the GD ORB compliance team is investigating this case.

With regards to issue IRR-012-GDPF and FCA permissions, one Provider suggested that some
Providers have lost a proportion of the supply chain who are deterred from involvement in the
Green Deal due to the requirement to have FCA permissions.
The group agreed to follow up on issues after the election in May.
9.
AOB
There was no further business and the Chair closed the meeting.
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Annex A
ACTIONS OUTSTANDING
Action Ref
Description
By Who
Date of
completion
Update
Post-meeting note:
DECC have published carbon savings from GDHIF as
part of our quarterly Green Deal and ECO stats release.
The latest quarterly release can be found here (see
Table 1.15):
https://www.gov.uk/government/statistics/green-dealenergy-company-obligation-eco-and-insulation-levelsin-great-britainquarterly-report-to-december-2014
Action GDPF
09-02
DECC to raise Provider concerns regarding the
need to undertake technical monitoring of
GDHIF installations in order to verify carbon
reduction savings, and report back the Forum
on what steps are being taken.
DECC
23/04/2015
The methodology behind how the carbon savings are
calculated can be found in the following methodology
note (page 29 covers GDHIF):
https://www.gov.uk/government/statistics/domesticgreen-deal-and-eco-statistics-methodology-note
The Scheme Administrator currently conducts on-site
audits of a proportion of properties under GDHIF to
ensure that energy efficiency measures have been
installed (and therefore assumed carbon-saving
realised), and there are further provisions for additional
technical monitoring.
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This action is closed.
Action GDPF
09-05
Action GDPF
150327-01
Action GDPF
150327-02
Action GDPF
150327-03
DECC to clarify and provide written
confirmation of the Ombudsman
arrangements for Green Deal Providers.
GD ORB to circulate a communication to
Providers clarifying the Consumer Contracts
Regulations (CCR) requirement of 14 day
calling off period and provide a best practice
example of expressed consent form.
DECC to revise the DECC news bulletin
Assessment of Boilers – HHCRO and Green
Deal and GD ORB to re-circulate the
communication clarifying the change.
GD ORB to clarify with DECC whether
European Regional Development Funding can
be blended with ECO and/ or the Green Deal
and report back to the forum.
DECC
22/05/2015
The Green Deal Ombudsman Service has provided a
written statement clarifying the investigation fees
protocol between the Green Deal and Financial
Ombudsman. The FOS Policy Director is to be installed
in the near future, following which further clarification
on subscription fees will be provided to Providers.
GD ORB
22/05/2015
The communication is under development and is
expected to be circulated shortly.
DECC / GD
ORB
22/05/2015
Final wording of bulletin is being agreed. It is intended
that the communication will be reissued with an
additional statement to clarify imminently.
22/05/2015
A guidance document on blending various energy
efficiency schemes and funding streams is under
development.
GD ORB /
DECC
ACTIONS CLOSED AT THE MEETING
Action Ref
Description
By Who
Date of
completion
Update
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Action GDPF
09-03
DECC to raise issue of product warranties
undermining IBGs internally with the
appropriate team, and report back the
Provider Forum.
Action GDPF
09-04
GD ORB and DECC to clarify the implications
of the Consumer Contract Regulations for the
DECC/GD
Green Deal and report back to the Provider
ORB
Forum on how these regulations can be met in
practice.
DECC
27/03/2015
27/03/2015
Initial feedback on the issue has been collected and
reported to DECC.
Provider Forum members were invited to confirm
whether additional evidence on the issue needs to be
collected and submitted to DECC and it was agreed that
this is not necessary. The action was closed at the 27th
March meeting.
GD ORB provided an update to Provider Forum
members at the 27th March GDPF meeting. GD ORB
agreed to circulate a communication to Providers
clarifying the requirements. The action was closed at
the 27th March meeting.
ACTIONS CLOSED SINCE THE PREVIOUS MEETING
Action Ref
Description
By Who
Date of
completion
Action
GDPF09-01
Provider Forum members to draft a letter to
the GDFC to request confirmation that the
GDFC Green Deal Plan documentation has
been approved by the FCA.
Provider
Forum
13/03/2015
Action
GDPF09-06
The GD ORB to arrange a teleconference for
Provider Forum members to have an initial
discussion on the Provider/GDFC service level
agreements.
GD ORB
19/02/2015
Update
A letter has been drafted by a number of Provider
Forum members, which has been circulated to the
Provider Forum for comment and to request
confirmation of support (supporting Providers will are
signatories to the letter). The letter will be sent to the
Green Deal Finance Company (GDFC) and be
accompanied by GDFC Service Level Agreement (SLA)
Strawman. Please see Action GDPF 09-06.
A teleconference was organised on the 19th February.
Feedback on the 'Strawman' document was taken to be
incorporated. Further feedback was sought and
incorporated from the Provider Forum Co-chairs. The
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'Strawman' has been circulated to the Provider Forum
members for comment, alongside a supporting letter
(Please see Action 09-01).
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